Antitrust sanctions on extraterritorial conducts in the United States and the European Union

Abstract

This article discusses the United States and European Union’s sanctioning powers over extraterritorial antitrust infringements that affect their internal markets. It remarks the domestic sanction of those actions on the ground that they have produced an adverse impact on the domestic territory, which must be substantial and direct. In addition, it identifies some deferential or comity criteria which contributes to conciliate jurisdictional interests affected by cross border infringements.